PRIVACY POLICY

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1. INTRODUCTION

This Privacy Policy explains how acouncilbility ("we," "us," or "our") collects, uses, discloses, and protects your personal information when you use our mobile application and services (collectively, "Services").

acouncilbility is a civic reporting platform that allows users to submit reports about infrastructure, services, and community issues to government authorities and responsible organizations.

We are committed to protecting your privacy while providing transparent civic accountability tools. This Policy is designed to comply with:

• Privacy Act 1988 (Cth) and Australian Privacy Principles
• General Data Protection Regulation (GDPR) where applicable
• Google Play Store and Apple App Store privacy requirements
• Notifiable Data Breaches scheme requirements

2. INFORMATION WE COLLECT

2.1 Information Collection Overview

We collect minimal information necessary to provide our civic reporting services. We do not collect personal information in traditional ways and do not maintain profiles with names, email addresses, or phone numbers.

2.2 Data We Collect When You Submit Reports

Data Type	Collection Method	Purpose
Location Coordinates	Manual selection, GPS capture during submission, or EXIF data from photos	Essential for report routing and public accountability mapping
Report Content	Text descriptions you write	Communicating the issue to responsible authorities
Photographs	Images you choose to include	Visual documentation for authorities and public accountability
Account Hash	Generated from your 12-word seed phrase	Anonymous account identification and report attribution
Device Metadata	Technical information during submission	Report processing and technical support
Timestamps	Automatically captured during submission	Report tracking and authority processing

2.3 Data We Do NOT Collect

• Personal Identity: No names, email addresses, phone numbers, or traditional identifying information
• Background Location: No continuous or passive location tracking when the app is not actively being used for reporting
• Browsing Data: No web browsing history, search queries, or app usage outside of report submission
• Contact Lists: No access to your contacts, messages, or communication data
• Financial Data: No payment information, banking details, or transaction data
• Social Media: No social media profiles, posts, or connections
• Device Content: No access to files, photos, or data outside of what you explicitly include in reports

3. ANONYMOUS ACCOUNT SYSTEM

3.1 Cryptographic Seed Phrase Technology

Our privacy-by-design approach uses a cryptographically secure anonymous account system:

• 12-Word Seed Phrase: You generate a cryptographically random 12-word phrase during account creation
• 24-Character Hash: Your seed phrase creates a unique anonymous identifier
• RSA2048 Key Generation: Your device generates public and private key pairs from your seed phrase using RSA2048 cryptography
• Private Key Protection: Your private keys never leave your device and are never transmitted to our servers
• Public Key Vault: Your public key is uploaded to our secure storage vault for encryption purposes
• No Personal Data Storage: We never store names, emails, phone numbers, or other traditional personal identifiers
• User-Controlled Recovery: Only you control your seed phrase and account access

3.2 Account Privacy Benefits

• Complete anonymity in public reports (only the anonymous hash is visible)
• Zero-knowledge encryption for private reports (we cannot read encrypted content)
• No linkage to your real-world identity unless you choose to include it in report content
• Protection from data breaches affecting personal identification
• Cryptographic-grade user-controlled account recovery
• Military-grade security for sensitive civic reporting

4. HOW WE USE YOUR INFORMATION

4.1 Primary Use Purposes

• Report Processing: Creating, validating, and transmitting civic reports to responsible authorities
• Authority Routing: Determining and contacting the appropriate government body or organization
• Public Accountability: Displaying public reports on maps and databases for community transparency
• Service Functionality: Ensuring technical operation of the platform

4.2 Public vs Private Reports

Public Reports:

• Location coordinates, descriptions, and photos are displayed on public maps
• Available to all users, government authorities, journalists, and researchers
• Permanent public record for accountability and transparency
• Anonymous account hash visible (not linked to personal identity)

Private Reports (Zero-Knowledge Encrypted):

• Military-Grade Encryption: Content encrypted with hybrid AES256 + RSA2048 encryption on your device
• Zero-Knowledge Security: Only the intended government authority can decrypt and read report content
• acouncilbility Cannot Read: We cannot access, view, or decrypt private report content - ensuring complete privacy
• Authority-Only Access: Transmitted securely to responsible authority using their public key
• Not displayed on public maps or user feeds
• Report metadata (category, date, authority) retained for operational records
• Subject to authority's own disclosure policies and Freedom of Information laws

5. INFORMATION SHARING AND DISCLOSURE

5.1 Government and Authority Sharing

We share report information with responsible authorities including:

• Local Government: City councils, county authorities, municipal governments
• State Government: State departments, agencies, and statutory authorities
• Federal Government: Commonwealth departments and agencies
• Public Utilities: Water, electricity, gas, telecommunications providers
• Private Contractors: Companies providing public services or managing public infrastructure
• Emergency Services: When reports indicate urgent public safety matters

5.2 Legal Basis for Sharing

Information sharing occurs under the following legal bases:

• Explicit Consent: You consent when submitting reports through mandatory acknowledgments
• Public Interest: Civic accountability and transparency serve legitimate public interests
• Legal Compliance: Cooperation with law enforcement and regulatory requirements
• Service Provision: Report routing is essential to platform functionality

5.3 Public Disclosure for Public Reports

5.4 Third-Party Service Providers

We may share technical data with:

• Cloud Hosting Services: For secure data storage and platform operation
• Mapping Services: For location display and geographic functionality
• Analytics Providers: For platform usage statistics (aggregated and anonymized only)
• Security Services: For fraud prevention and platform protection

All service providers are contractually required to maintain data security and use limitations.

6. LOCATION DATA AND MAPPING

6.1 Location Collection

Location information is collected ONLY when you actively submit a report through:

• Manual Selection: Location coordinates you choose on the map interface
• Current Location: GPS coordinates you authorize the app to capture during report creation
• Photo Metadata: EXIF location data embedded in photographs you include in reports

6.2 Location Data Usage

• Report Mapping: Displaying exact location of reported issues on public maps (for public reports)
• Authority Routing: Determining jurisdiction and responsible organization
• Geographic Analysis: Enabling area-based reporting trends and patterns
• Public Accountability: Allowing community monitoring of local issues and government response

6.3 Location Privacy Limitations

7. DATA RETENTION

7.1 Report Data Retention

• Public Reports: Retained permanently as part of public civic record for accountability and transparency
• Private Reports: Content provided to authorities as required; metadata retained for operational records
• Account Information: Anonymous hash retained while account remains active
• Technical Logs: Retained for 12 months for security and technical support purposes

7.2 Legal and Public Interest Basis

Long-term retention is justified by:

• Public accountability and transparency requirements
• Historical record preservation for civic improvement
• Government authority access needs
• Research and analysis for public policy development
• Legal compliance with record-keeping obligations

7.3 Account Deactivation

When you deactivate your account:

• Your account hash becomes inactive
• You cannot submit new reports
• Previously submitted public reports remain permanently available
• Previously submitted private reports remain accessible to authorities
• No personal data deletion is possible as reports become part of public or operational records

8. YOUR PRIVACY RIGHTS

8.1 Australian Privacy Rights

Under the Privacy Act 1988 (Cth), you may have rights to:

• Access: Request access to personal information we hold about you
• Correction: Request correction of inaccurate personal information
• Complaint: Lodge complaints about our privacy practices

8.2 Limitations on Privacy Rights

8.3 GDPR Rights (EU Users)

If you are located in the European Union, you may have additional rights under GDPR, including:

• Right of access to your personal data
• Right to rectification of inaccurate data
• Right to erasure (limited by public interest and legal obligations)
• Right to data portability
• Right to object to processing

These rights are subject to limitations for public interest activities and legal compliance requirements.

9. DATA SECURITY

9.1 Military-Grade Encryption

We implement military-grade security measures that exceed industry standards:

9.2 Advanced Cryptographic Architecture

• Device-Generated Keys: Public and private key pairs generated locally on your device from your 12-word seed phrase
• Private Keys Never Leave Device: Your private keys remain exclusively on your device and are never transmitted or stored on our servers
• Authority Key Management: Government authority public keys (derived from their master seed controlled by senior officials) are stored in our secure vault
• End-to-End Encryption: Private reports are encrypted on your device and can only be decrypted by the intended authority
• Perfect Forward Secrecy: Each report uses unique encryption ensuring past communications remain secure even if future keys are compromised

9.3 Transport Layer Security

• Latest TLS Encryption: All data transmission protected by the latest Transport Layer Security (TLS) protocols
• HTTPS Enforcement: All communications between app and servers use HTTPS with current TLS standards
• JWT Token Security: Authentication tokens use the latest JSON Web Token (JWT) standards with cryptographic signing
• End-to-End Protection: Data protected during transmission from device to server and from server to authorities
• Certificate Management: Regular SSL/TLS certificate updates and security monitoring
• Protocol Standards: Compliance with current IETF standards for secure communication

9.4 Infrastructure Security

• JWT Authentication: Secure token-based authentication system protecting all API endpoints
• NginX Reverse Proxy: Advanced proxy protection preventing direct access to application servers and filtering malicious requests
• Multi-Level Directory Structure: Data stored in advanced hierarchical folder system with granular permission controls
• JSON Storage Architecture: No traditional database vulnerabilities - data stored as JSON eliminating SQL injection and database-specific attack vectors
• Code Obfuscation: Mobile application compiled with advanced obfuscation protecting against reverse engineering
• No Third-Party Database Dependencies: Custom storage system eliminates vulnerabilities from third-party database software

9.5 Additional Security Measures

• Endpoint Protection: All API endpoints protected by authentication and authorization layers
• Input Validation: Comprehensive server-side validation preventing injection attacks
• Access Logging: Complete audit trail of all system access and data operations
• Regular Security Audits: Ongoing penetration testing and security assessments
• Secure Development: Security-first development practices and code review processes

9.6 Data Breach Response

In the event of a data breach, we will:

• Assess the breach within 72 hours
• Notify the Office of the Australian Information Commissioner if required
• Notify affected users if there is likely risk of serious harm
• Take immediate steps to secure systems and prevent further breaches
• Provide breach details as required by the Notifiable Data Breaches scheme

10. CHILDREN'S PRIVACY

10.1 Age Restriction

Our Services are intended for users aged 18 and above only. We do not knowingly collect personal information from children under 18.

10.2 Child Privacy Protection

If we discover that a child under 18 has provided personal information:

• We will delete the information as soon as reasonably possible
• We will deactivate the account
• We will not share the information with third parties (except as legally required)
• Parents or guardians should contact us immediately if they believe their child has used our Services

11. INTERNATIONAL DATA TRANSFERS

11.1 Cross-Border Transfers

Your data may be transferred to and stored in countries other than your country of residence, including:

• Cloud hosting services in various jurisdictions
• Government authorities in other Australian states or territories
• International organizations working with Australian authorities

11.2 Transfer Protections

International transfers are protected through:

• Contractual safeguards with service providers
• Compliance with Australian privacy law requirements
• GDPR adequacy decisions where applicable
• Standard contractual clauses for EU data transfers

12. THIRD-PARTY INTEGRATIONS

12.1 Government Authority Systems

We integrate with various government systems for report submission. These authorities have their own privacy policies and data handling practices that we cannot control.

12.2 Mapping and Location Services

Our app may use third-party mapping services for location selection and display. These services operate under their own privacy policies.

12.3 Analytics and Performance

We may use privacy-compliant analytics services to monitor:

• App performance and technical issues
• Aggregated usage statistics (no personal data)
• System reliability and error reporting

13. COOKIES AND TRACKING

13.1 Mobile App Data Storage

Our mobile app may store technical data locally on your device including:

• App preferences and settings
• Temporary data for app functionality
• Offline capability data (if applicable)

13.2 Website Cookies (if applicable)

Our website may use minimal cookies for:

• Essential website functionality
• Security and fraud prevention
• Anonymous analytics (with user consent where required)

We do not use advertising cookies or tracking cookies for marketing purposes.

14. LEGAL COMPLIANCE AND LAW ENFORCEMENT

14.1 Legal Disclosure

We may disclose information when required by law, including:

• Court orders, subpoenas, or search warrants
• Law enforcement investigations
• Regulatory compliance requirements
• eSafety Commissioner directives
• Child protection or public safety emergencies

14.2 Government Access

Government authorities may access report data through:

• Direct report transmission (as intended platform function)
• Legal process requiring disclosure
• Public records access (for public reports)
• Freedom of Information requests (subject to applicable exemptions)

15. YOUR CHOICES AND CONTROLS

15.1 Report Privacy Selection

For each report, you can choose:

• "Public Report": Visible on public maps and accessible to all
• "Private Report": Transmitted only to responsible authority

Note: This choice cannot be changed after submission.

15.2 Location Data Control

You control location inclusion by:

• Choosing whether to enable location services during report creation
• Manually selecting location on map interface
• Removing EXIF data from photos before including them
• Deciding whether to include photographs with location metadata

15.3 Account Management

• Account Deactivation: You can deactivate your account at any time through the app settings
• Data Download: You can view your report history through the app interface
• Seed Phrase Security: You control your seed phrase and account recovery

16. DATA PROTECTION COMPLIANCE

16.1 Australian Privacy Principles Compliance

We exceed Australian Privacy Principles requirements through advanced technical measures:

• APP 1: Open and transparent management with military-grade security disclosure
• APP 3: Minimal collection with cryptographic protection
• APP 5: Clear notification with detailed encryption explanations
• APP 6: Controlled use with zero-knowledge architecture for private reports
• APP 8: Secure cross-border disclosure with end-to-end encryption
• APP 11: Military-grade security and controlled retention
• APP 12: Secure access with cryptographic account controls

16.2 Enhanced Security Compliance

Our security architecture exceeds regulatory requirements:

• Zero-Knowledge Privacy: Private reports protected beyond legal requirements - we cannot access encrypted content even if legally required
• Cryptographic Compliance: Military-grade encryption standards exceed data protection requirements
• Anonymous Architecture: Seed phrase system provides stronger privacy than traditional approaches
• Infrastructure Security: Custom security stack eliminates common vulnerabilities

16.2 Lawful Basis Documentation

We maintain documentation of lawful bases for processing including:

• User consent records through mandatory acknowledgments
• Public interest justifications for transparency services
• Legal obligation compliance records
• Legitimate interest assessments for service provision

17. APP STORE SPECIFIC DISCLOSURES

17.1 Google Play Store Compliance

This app exceeds Google Play privacy and security requirements:

• Data Safety Section: All data collection practices accurately disclosed with enhanced security measures
• Military-Grade Encryption: AES256 + RSA2048 hybrid encryption for private reports
• Zero-Knowledge Architecture: Private report content cannot be accessed by app developers
• Sensitive Permissions: Location permission used only for report submission, never background tracking
• Advanced Security: JWT authentication, NginX protection, and obfuscated compilation
• User Control: Cryptographic user control over all data and account access

17.2 Apple App Store Compliance

This app exceeds Apple App Store privacy and security requirements:

• Privacy Nutrition Labels: Accurate representation of minimal data collection with maximum security
• iOS Privacy Framework: Full compliance with iOS permission systems and App Tracking Transparency
• Data Minimization: Collection limited to essential functionality with military-grade protection
• Encryption Standards: AES256 + RSA2048 encryption exceeds Apple's security recommendations
• No Third-Party Vulnerabilities: Custom JSON storage eliminates database-related security risks

17.3 Enhanced Security Features for App Stores

• Code Protection: Application compiled with advanced obfuscation preventing reverse engineering
• API Security: NginX reverse proxy protection with JWT authentication for all endpoints
• File System Security: Multi-level directory structure with granular folder permissions
• Attack Vector Prevention: No SQL database eliminates injection vulnerabilities
• Cryptographic Standards: Implementation follows industry best practices for key generation and management

18. CONTACT AND COMPLAINTS

18.1 Privacy Officer Contact

For privacy-related questions, complaints, or requests:

Email: privacy@acouncilbility.org
Website: https://acouncilbility.org/privacy
Response Time: We aim to respond to privacy inquiries within 30 days

18.2 Privacy Complaint Process

1. Internal Complaint: Contact our privacy officer first
2. Investigation: We will investigate your complaint within 30 days
3. Response: We will provide a written response with our decision
4. External Review: If unsatisfied, you may complain to the Office of the Australian Information Commissioner

18.3 Regulatory Contact Information

Office of the Australian Information Commissioner:
Website: https://www.oaic.gov.au
Phone: 1300 363 992
Email: enquiries@oaic.gov.au

19. UPDATES TO THIS PRIVACY POLICY

19.1 Policy Changes

We may update this Privacy Policy to reflect:

• Changes in data protection laws
• New features or services
• Enhanced privacy practices
• Regulatory requirements

19.2 Notification of Changes

• In-App Notification: Users will be notified of significant changes through the app
• Website Publication: Updated policies posted on our website
• Effective Date: All changes include clear effective dates
• Continued Use: Using the service after updates constitutes acceptance

20. ADDITIONAL INFORMATION

20.1 Privacy by Design

Our platform is built with privacy-by-design principles:

• Minimal data collection by default
• Anonymous account system protecting user identity
• User control over public vs private reporting
• No unnecessary tracking or profiling
• Transparent data handling practices

20.2 Civic Transparency Balance

We balance privacy protection with civic accountability by:

• Providing clear choices between public and private reporting
• Using anonymous account systems
• Collecting only data essential for service functionality
• Ensuring transparent government authority access
• Maintaining public accountability through mapping and reporting

This Privacy Policy was last updated on 25/08/2025. We recommend users regularly review this Policy for any updates or changes.